The Accountable Care Organization

Size: px
Start display at page:

Download "The Accountable Care Organization"

Transcription

1 The Accountable Care Organization Kim Harvey Looney

2 ACOs: Will I Know One When I See One? Relatively New Concept Derived from Various Demonstration Programs No Set Structure ACO is a Goal, not Necessarily a Mechanism 2

3 Physician Group Practice (PGP) Demonstration Project Initiated by CMS in April 2005 Offered 10 large practices opportunity to earn performance payments for improving the quality and cost-efficiency of health care delivered to Medicare fee-for-service beneficiaries 3

4 PGP Demonstration Program Billings Clinic: Billings, MT Dartmouth-Hitchcock Clinic: Bedford, NH The Everett Clinic: Everett, WA Forsyth Medical Group: Winston-Salem, NC Geisinger Health System: Danville, PA Marshfield Clinic: Marshfield, WI Middlesex Health System: Middletown, CT Park Nicollet Health Services: St. Louis Park, MN St. John s Health System: Springfield, MO University of Michigan Faculty Group Practice: Ann Arbor, MI 4

5 PGP Demonstration Results All physician groups improved clinical management of patients Some physician groups saved CMS money and shared in savings Year 3: 5 groups shared in 25.3 M savings for achieving 2% per year reductions in spending growth below control populations Program provided initial insight into ability of physicians to manage a population of patients (FFS) 5

6 Healthcare Reform: Patient Protection and Affordable Care Act Shift in the reimbursement system from traditional FFS payment toward a more riskbased approach to payment or accountable payment. Create incentives for providers to become more coordinated, more integrated, more reliable, lower cost, and more focused on treating chronic disease in a sustainable way. No more the more care you provide, the more money you make and hospitals will need to work to keep people out of the hospital 6

7 What Are ACOs? Entity willing to become accountable for the quality, cost, and overall care of Medicare FFS beneficiaries assigned to it Expected to meet specific organizational and quality performance standards (still to be determined) If standards met, eligible to receive cost sharing 7

8 ACA: Who Can Be an ACO? Physicians in group practice arrangements Networks of individual practices of physicians Partnerships or joint venture arrangements between hospitals and physicians Hospitals and their employed physicians Such other groups of providers of services and suppliers as the Secretary determines appropriate 8

9 Accountable Care Organizations Providers continue to submit individual claims and be paid separately. If targets are met, the ACO receives back-end percentage of the shared savings which are shared across providers. a percent (as determined appropriate by the Secretary) of the difference between such estimated average per capita Medicare expenditures in a year, adjusted for beneficiary characteristics, under the ACO and such benchmark for the ACO may be paid to the ACO as shared savings and the remainder of such difference shall be retained by the program under this title. The Secretary shall establish limits on the total amount of shared savings that may be paid to an ACO under this paragraph. H.R. 3590: Patient Protection and Affordable Care Act 9

10 Accountable Care Organizations Division of savings between ACO and Medicare is unspecified ACO organizations responsible for determining how savings split among themselves Secretary authorized, but not required, to use other payment models Partial capitation arrangement under which highly integrated care systems assume full financial risk in return for fixed monthly payment per beneficiary Risk corridors ACOs potential for profit or loss is limited 10

11 Accountable Care Organizations Must establish a mechanism for shared governance and formal legal structure to receive and distribute payments for shared savings Prohibited from taking steps to avoid patients at risk in order to reduce likelihood of increasing costs to ACO Secretary may impose sanctions on ACO that tries to avoid such patients, up to and including termination from Medicare program 11

12 ACO in Healthcare Reform Legislation ACOs will be eligible to receive a percentage of the cost savings that they have realized under the traditional feefor-service Medicare system ACO shall enter into a three-year agreement with HHS whereby the ACO must agree to contain at least 5,000 Medicare beneficiaries, while being prevented from engaging in risk selection ACO must define processes to promote evidence-based medicine and patient engagement, report on quality and cost measures, and coordinate care, such as through the use of telehealth or other remote patient monitoring tools ACO must also demonstrate to HHS that it meets defined criteria for patient-centered care 12

13 It s Going to Be All about Quality ACOs need to have the ability to capture and report data, at the group and individual provider level, relating to measures necessary to evaluate the quality of care furnished ACOs will be expected to meet third party (e.g. Medicare) performance standards measuring the quality of care furnished The bar will not be static ACOs will be expected to improve the quality of care furnished over time by meeting ever increasing standards for purposes of assessing quality of care To earn incentive payment, the ACO will be expected to meet certain quality thresholds 13

14 Potential Issues with ACOs Anti-Kickback Statute and CMP Law Requirement of hospitals, physicians and other providers to accept one payment for services and share financial incentives could be in violation of previous interpretations Antitrust consequences Uncertainty may deter precompetitive, innovative arrangements Nonprofit hospitals Determine whether involvement with for-profit physician practices complies with IRS guidelines for nonprofit institutions 14

15 Center for Medicare and Medicaid Innovation New entity within CMS established by ACA Has authority to test proposed methods of coordinated care delivery such as ACOs 15

16 Center for Medicare and Medicaid Innovation To test innovative payment and service delivery models to reduce program expenditures while preserving or enhancing the quality of care furnished to individuals Preference to be given to models that also improve the coordination, quality, and efficiency of healthcare services The CMI shall consult representatives of relevant Federal agencies, and clinical and analytical experts with expertise in medicine and health care management Use open door forums or other mechanisms to seek input from interested parties Select models to be tested from models where the Secretary determines that there is evidence that the model addresses a defined population for which there are deficits in care leading to poor clinical outcomes or potentially avoidable expenditures 16

17 Challenges for ACOs Critical mass of provider participation Critical mass of payor participation Adequate financing for ACO start-up costs: IT, analytic capabilities, clinical support infrastructure, time and effort Technical issues patient assignment algorithm, performance measures and budgeting methodology Changing provider culture and patient behavior Medicare: No enrollment, no lock-in, no change in benefits Modest financial incentives (at least with Level I shared savings) 17

18 Notice of Proposed Rulemaking Draft regulation for shared savings program for ACOs in the fall of 2010 (December or January) CMS currently soliciting input from providers, patient advocacy groups and other stakeholders Written comments or statements may be sent via e- mail to: or sent via regular mail to: Attn: ACO Legal Issues, Mail Stop C , Centers for Medicare & Medicaid Services, 7500 Security Boulevard, Baltimore, MD

19 Systems Implementing ACOs Kaiser Permanente: integrated model, 35 hospitals employ 14,000 physicians, thereby removing incentives for providers to over-utilize care, Kaiser has also improved clinical outcomes for chronic disease patients under coordinated care model Geisinger Health System: Charges flat rate for coronary bypass procedures, which has reduced readmission rates and cost of care Baylor Health Care System: Converting 13 of its 26 hospitals to an ACO model by 2015 Montefiore: 2,500 salaried physicians, including 500 communitybased primary care to provide unified system of care. Enrolled 150,000 members under its own HMO. Flat annual fee. Extensive EHR system. Piedmont: Piedmont Physicians Group and Cigna launch an ACO pilot program in Atlanta for better care coordination in September

20 Secretary of HHS Required to establish shared savings program specifically relating to ACOs no later than January 1, 2012 Final authority over: Establishment of quality performance standards and assessment of ACO s performance Assignment of Medicare fee-for-service beneficiaries to ACO Determination of whether ACO eligible for shared savings and amount of shared savings

21 BUT, ACA does: Permit Secretary of HHS to waive requirements of Anti-kickback Statute, Stark and CMP laws as necessary to administer ACOs 21

22 You ve Got a Friend in Me 22 22

23 FTC Chairman Jon Leibowitz FTC will consider New Safe Harbors for ACO Arrangements FTC will consider establishing Expedited Review Process 23 23

24 HHS Inspector General Daniel Levinson Fraud and abuse laws should not stand in the way of provider innovation to improve quality and reduce costs OIG looking closely at how HHS Secretary can effectively use the waiver authority to develop new safe harbors and regulatory exception to facilitate ACO development 24 24

25 CMS Administrator Don Berwick ACO Goals Improving individual patient care Improving the health of communities Lowering the cost of healthcare services without any diminution in quality 25

26 Comparison of Payment Reform Models (The Dartmouth Brookings Accountable Care Organization Learning Network) ACOs Medical Home Bundled Payments 26

27 Comparison of Payment Reform Models (The Dartmouth Brookings Accountable Care Organization Learning Network) ACOs Medical Home Bundled Payments 27

28 NCQA Draft ACO Criteria Whether the criteria should specify the types of specialists that should be included in the ACO and, if so, whether the specialists must be part of the organization s legal structure. The capabilities that should be expected for each of the four proposed ACO levels. Whether the eligibility criteria proposed by NCQA capture the organization types that have the capability to act as ACOs. Whether the criteria align with stakeholder expectations for ACOs and whether the criteria fails to address areas that should be included. Whether organizations seeking to become ACOs will be able to demonstrate compliance with the criteria, and, if not, which areas of the criteria will be most challenging. Whether there are critical functions not included in the current draft standards. Note: Deadline for comments November

29 Some say accountable care organizations are like unicorns they want to believe in them, but they ve never seen one. 29

30 Others say ACOs do exist and they know this because they have seen them in California. 54% of insured population in California covered by ACO-like arrangements. Modern Healthcare Cover Story, November 1,

31 ACO Lessons Learned in California Structure is important, but at least as important as structure is an organization s capabilities, culture, and infrastructure, as well as the alignment of goals between the organization and its individual physicians. Alignment of incentives between physician organizations and hospitals offer important opportunities for performance improvements across the entire continuum of care. Capitation can be effective, but payment methods should vary depending on ACO s ability to assume risk. Note: Fee for service payment with shared savings has not been successful for efficient delivery of care. Health plans working together on payment methods and performance measures helped facilitate growth of ACOs in California. 31

32 ACO Lessons Learned in California ACOs are not the be all/end all for healthcare spending control. ACOs must be agnostic to insurance type. Difficult to balance patient choice with the desire to decrease costs and effectively coordinate care. Regulation of the financial solvency of provider organizations is important to ensure market stability. Consumer protections from capitated provider organizations need to be balanced, not overburdening. Establish ACOs in geographic areas with identifiable social and economic challenges. 32

Reforming Provider Payments:

Reforming Provider Payments: Reforming Provider Payments: A Critical Step for Better Health Care and Lower Costs Aaron McKethan, PhD Engelberg Center for Health Care Reform The Brookings Institution January 8, 2010 Regional Variations

More information

Statement of the Association of American Medical Colleges on Legal Issues Related to Accountable Care Organizations and Healthcare Innovation Zones

Statement of the Association of American Medical Colleges on Legal Issues Related to Accountable Care Organizations and Healthcare Innovation Zones Statement of the Association of American Medical Colleges on Legal Issues Related to Accountable Care Organizations and Healthcare Innovation Zones Public Workshop hosted by the FTC, CMS, HHS OIG October

More information

Additional Information About Accountable Care Organizations

Additional Information About Accountable Care Organizations Additional Information About Accountable Care Organizations For more information, please contact: April 2011 On March 31st, the federal government outlined proposed actions relating to Accountable Care

More information

CMS Releases Proposed Rule Governing Accountable Care Organizations

CMS Releases Proposed Rule Governing Accountable Care Organizations CMS Releases Proposed Rule Governing Accountable Care Organizations Health Care Organizations Face Complex Strategic Decisions Authors: Robert D. Belfort Paul M. Campbell Susan R. Ingargiola Stephanie

More information

Federal Health Care Reform: Implications for Hospital and Physician partnerships. Walter Kopp Medical Management Services

Federal Health Care Reform: Implications for Hospital and Physician partnerships. Walter Kopp Medical Management Services Federal Health Care Reform: Implications for Hospital and Physician partnerships Walter Kopp Medical Management Services Outline Overview of federal health reform legislation Implications for Care delivery

More information

NATIONAL ASSOCIATION OF COMMUNITY HEALTH CENTERS. Briefing Paper on the Proposed Medicare Shared Savings Program

NATIONAL ASSOCIATION OF COMMUNITY HEALTH CENTERS. Briefing Paper on the Proposed Medicare Shared Savings Program NATIONAL ASSOCIATION OF COMMUNITY HEALTH CENTERS Briefing Paper on the Proposed Medicare Shared Savings Program The Centers for Medicare and Medicaid Services (CMS) recently issued a proposed rule to implement

More information

The true meaning of ACO is Awesome Consulting Opportunities. - The Weekly Standard, 04/12/11. Consultants

The true meaning of ACO is Awesome Consulting Opportunities. - The Weekly Standard, 04/12/11. Consultants Accountable Care Organizations: Proposed Regulations and the Local Landscape May 26, 2011 John Clark, MD, JD Isaac M. Willett Medical Director, Clinical i l Informatics Attorney Indiana University Health

More information

PROPOSED MEDICARE SHARED SAVINGS (ACO) PROGRAM RULES

PROPOSED MEDICARE SHARED SAVINGS (ACO) PROGRAM RULES PROPOSED MEDICARE SHARED SAVINGS (ACO) PROGRAM RULES The Centers for Medicare and Medicaid Services (CMS) and other affected agencies released their notice of proposed rulemaking/request for comment for

More information

2010 MHA Governance Leadership Forum: Accountable Care Organizations. Chris Rossman, Esq. Foley & Lardner LLP Detroit, Michigan

2010 MHA Governance Leadership Forum: Accountable Care Organizations. Chris Rossman, Esq. Foley & Lardner LLP Detroit, Michigan 2010 MHA Governance Leadership Forum: Accountable Care Organizations Chris Rossman, Esq. Foley & Lardner LLP Detroit, Michigan Overview Major health care payment reform under the Affordable Care Act (

More information

Alan K. Parver Darryl Drevna SUBJECT: Accountable Care Organizations DATE: August 24, 2010

Alan K. Parver Darryl Drevna SUBJECT: Accountable Care Organizations DATE: August 24, 2010 TO: FROM: Alan K. Parver Darryl Drevna SUBJECT: Accountable Care Organizations DATE: August 24, 2010 The following is an overview of Accountable Care Organizations (ACOs), a shared savings program used

More information

HEALTH REFORM LAW: ACCOUNTABLE CARE ORGANIZATIONS

HEALTH REFORM LAW: ACCOUNTABLE CARE ORGANIZATIONS HEALTH REFORM LAW: ACCOUNTABLE CARE ORGANIZATIONS PRESENTED AT THE NASABA 2011 CONVENTION BY: PURVI B. MANIAR Context and Background Patient Protection and Affordable Care Act of 2010 ( PPACA ) (Section

More information

NATIONAL ASSOCIATION OF COMMUNITY HEALTH CENTERS. Briefing Paper on the Proposed Medicare Shared Savings Program

NATIONAL ASSOCIATION OF COMMUNITY HEALTH CENTERS. Briefing Paper on the Proposed Medicare Shared Savings Program NATIONAL ASSOCIATION OF COMMUNITY HEALTH CENTERS Briefing Paper on the Proposed Medicare Shared Savings Program The Centers for Medicare and Medicaid Services (CMS) recently issued a proposed rule to implement

More information

Fraud and Abuse Considerations for Accountable Care Organizations (ACOs)

Fraud and Abuse Considerations for Accountable Care Organizations (ACOs) Fraud and Abuse Considerations for Accountable Care Organizations (ACOs) By: Chris Rossman, Foley & Lardner LLP, Detroit, Michigan 1. The Centers for Medicare and Medicaid Services ( CMS ) and the Office

More information

Provider Participation in ACOs May Hinge on HHS Regulations

Provider Participation in ACOs May Hinge on HHS Regulations Source: Health Law Reporter: News Archive > 2010 > 04/15/2010 > BNA Insights > Provider Participation in ACOs May Hinge on HHS Regulations Provider Participation in ACOs May Hinge on HHS Regulations 19

More information

How Health Reform Will Affect Health Care Quality and the Delivery of Services

How Health Reform Will Affect Health Care Quality and the Delivery of Services Fact Sheet AARP Public Policy Institute How Health Reform Will Affect Health Care Quality and the Delivery of Services The recently enacted Affordable Care Act contains provisions to improve health care

More information

In early April, the Center for Medicare and Medicaid Services (CMS) issued

In early April, the Center for Medicare and Medicaid Services (CMS) issued April 26, 2011 If you have any questions regarding the matters discussed in this memorandum, please contact the following attorneys or call your regular Skadden contact. John T. Bentivoglio 202.371.7560

More information

KATHLEEN L. DEBRUHL & ASSOCIATES, L.L.C. 614 TCHOUPITOULAS STREET NEW ORLEANS, LOUISIANA 70130 504.522.4054 (OFFICE) 504.522.9049 (FAX) WWW.MD-LAW.

KATHLEEN L. DEBRUHL & ASSOCIATES, L.L.C. 614 TCHOUPITOULAS STREET NEW ORLEANS, LOUISIANA 70130 504.522.4054 (OFFICE) 504.522.9049 (FAX) WWW.MD-LAW. CMS RELEASES PROPOSED ACCOUNTABLE CARE ORGANIZATION REGULATIONS By: Kathleen L. DeBruhl, Esq. and Lindsey E. Surratt, Esq. On March 31, 2011, the Centers for Medicare and Medicaid Services ( CMS ) issued

More information

BAKER DONELSON BAKER S DOZEN

BAKER DONELSON BAKER S DOZEN Thirteen Things Health Care Providers Should Know About Accountable Care Organizations and Health Reform Thomas E. Bartrum, 615.726.5641, tbartrum@bakerdonelson.com With passage of the Patient Protection

More information

Accountable Care Organizations Understanding What They Are and How to Structure Them

Accountable Care Organizations Understanding What They Are and How to Structure Them Accountable Care Organizations Understanding What They Are and How to Structure Them Maria T. Currier HOLLAND & KNIGHT LLP Miami Chamber of Commerce Healthcare Subcommittee December 7, 2010 Copyright 2010

More information

II. SHARED SAVINGS PROGRAM AND COST-REDUCTION INCENTIVES

II. SHARED SAVINGS PROGRAM AND COST-REDUCTION INCENTIVES E-ALERT Health Care April 15, 2011 ACCOUNTABLE CARE ORGANIZATION BASICS The Affordable Care Act establishes the Medicare Shared Savings Program ( Program ), which provides for the development of accountable

More information

CMS proposed rule on ACOs: http://www.gpo.gov/fdsys/pkg/fr-2011-04-07/pdf/2011-7880.pdf

CMS proposed rule on ACOs: http://www.gpo.gov/fdsys/pkg/fr-2011-04-07/pdf/2011-7880.pdf April 7, 2011 Dear Physician Colleague: On March 31, 2011, the Centers for Medicare & Medicaid Services (CMS) issued its long awaited proposed regulations on the Medicare Shared Savings/Accountable Care

More information

Accountable Care Organization Provisions in the Patient Protection and Affordable Care Act

Accountable Care Organization Provisions in the Patient Protection and Affordable Care Act Accountable Care Organization Provisions in the Patient Protection and Affordable Care Act The consolidated Patient Protection and Affordable Care Act 1 is 974 pages long. Text related to Accountable Care

More information

RE: CMS-1345-P; Comments to Medicare Shared Savings Program: Accountable Care Organizations Proposed Rule

RE: CMS-1345-P; Comments to Medicare Shared Savings Program: Accountable Care Organizations Proposed Rule Centers for Medicare & Medicaid Services Department of Health and Human Services Attn: CMS-1345-P P.O. Box 8013 Baltimore, Maryland 21244-8013 RE: CMS-1345-P; Comments to Medicare Shared Savings Program:

More information

Advancing Accountable Care

Advancing Accountable Care Advancing Accountable Care Sean McBride Project Manager, Engelberg Center for Health Care Reform; Project Manager, ACO Learning Network Agenda 2. 4. Overview of national ACO Implementation: growing private

More information

Payor Perspectives on Provider Realignment and ACOs

Payor Perspectives on Provider Realignment and ACOs Payor Perspectives on Provider Realignment and ACOs Joel L. Michaels March 15, 2011 Overview Issues to be addressed Medicare Shared Savings Program overview ACO organization options Health care reform

More information

Accountable Care Organizations (ACO) Proposed Rule Summary March 31, 2011

Accountable Care Organizations (ACO) Proposed Rule Summary March 31, 2011 Accountable Care Organizations (ACO) Proposed Rule Summary March 31, 2011 On March 31, 2011, the Centers for Medicare & Medicaid Services (CMS) released the longawaited proposed rule on Accountable Care

More information

Fraud & Abuse Waivers Under the Medicare Shared Savings Program

Fraud & Abuse Waivers Under the Medicare Shared Savings Program Fraud & Abuse Waivers Under the Medicare Shared Savings Program Robert G. Homchick Davis Wright Tremaine, LLP I. Introduction The Patient Protection and Affordable Care Act of 2010 (ACA) fosters the development

More information

Accountable Care Organizations: What Providers Need to Know

Accountable Care Organizations: What Providers Need to Know DEPARTMENT OF HEALTH AND HUMAN SERVICES Centers for Medicare & Medicaid Services Accountable Care Organizations: FACT SHEET Overview http://www.cms.gov/sharedsavingsprogram On October 20, 2011, the Centers

More information

CLINICALLY INTEGRATED NETWORKS: BUSINESS AND LEGAL CONSIDERATIONS

CLINICALLY INTEGRATED NETWORKS: BUSINESS AND LEGAL CONSIDERATIONS CLINICALLY INTEGRATED NETWORKS: BUSINESS AND LEGAL CONSIDERATIONS Claire Turcotte, Esquire, Bricker & Eckler LLP Jim Yanci, MS MT (ASCP), Dixon Hughes Goodman Agenda BUSINESS CONSIDERATIONS How Fast are

More information

CMS - ACO Transitions Program

CMS - ACO Transitions Program CMS - ACO Transitions Program March 2011 Thomas R Graf MD Our Legacy Make my hospital right, make it the best. Abigail Geisinger 1827-1921 Geisinger Quality Striving for Perfection Geisinger Health System

More information

A Closer Look at the Final ACO Rule

A Closer Look at the Final ACO Rule A Closer Look at the Final ACO Rule October 2011 For more information, please contact: On October 20th, the federal government released a final rule and other companion releases relating to Accountable

More information

Healthcare Reform Update Conference Call VI

Healthcare Reform Update Conference Call VI Healthcare Reform Update Conference Call VI Sponsored by the Healthcare Reform Educational Task Force October 9, 2009 2:00-2:45 2:45 pm Eastern Healthcare Delivery System Reform Provisions in America s

More information

Nuts and Bolts of. Frank G. Opelka, MD FACS American College of Surgeons. Vice Chancellor for Clinical Affairs Professor of Surgery LSU New Orleans

Nuts and Bolts of. Frank G. Opelka, MD FACS American College of Surgeons. Vice Chancellor for Clinical Affairs Professor of Surgery LSU New Orleans Nuts and Bolts of Accountable Care Organizations Frank G. Opelka, MD FACS American College of Surgeons ACS Advocacy & Health Policy, Vice Chancellor for Clinical Affairs Professor of Surgery LSU New Orleans

More information

DETAILED SUMMARY--MEDCIARE SHARED SAVINGS/ACCOUNTABLE CARE ORGANIZATION (ACO) PROGRAM

DETAILED SUMMARY--MEDCIARE SHARED SAVINGS/ACCOUNTABLE CARE ORGANIZATION (ACO) PROGRAM 1 DETAILED SUMMARY--MEDCIARE SHARED SAVINGS/ACCOUNTABLE CARE ORGANIZATION (ACO) PROGRAM Definition of ACO General Concept An ACO refers to a group of physician and other healthcare providers and suppliers

More information

Entities eligible for ACO participation

Entities eligible for ACO participation On Oct. 20, 2011, the Centers for Medicare & Medicaid Services (CMS) finalized new rules under the Medicare Shared Savings Program (MSSP) to help doctors, hospitals, and other health care providers better

More information

Using Partial Capitation as an Alternative to Shared Savings to Support Accountable Care Organizations in Medicare

Using Partial Capitation as an Alternative to Shared Savings to Support Accountable Care Organizations in Medicare December 2010 Using Partial Capitation as an Alternative to Shared Savings to Support Accountable Care Organizations in Medicare CONTENTS Background... 2 Problems with the Shared Savings Model... 2 How

More information

Legal Issues for Accountable Care Organizations

Legal Issues for Accountable Care Organizations Legal Issues for Accountable Care Organizations Health Care Reform Strategies Bruce Merlin Fried, Esq. ACO Summit June 7, 2010 ACOs in PPACA The Basics Section 3022 of the Protection and Affordable Care

More information

Who, What, When and How of ACOs. Summary of proposed rule provisions for Accountable Care Organizations under the Medicare Shared Savings Program

Who, What, When and How of ACOs. Summary of proposed rule provisions for Accountable Care Organizations under the Medicare Shared Savings Program Who, What, When and How of ACOs Summary of proposed rule provisions for Accountable Care Organizations under the Medicare Shared Savings Program April 5, 2011 On March 31, 2011, the Centers for Medicare

More information

Accountable Care Organizations The Future Integrated Health Care Delivery Model?

Accountable Care Organizations The Future Integrated Health Care Delivery Model? Accountable Care Organizations The Future Integrated Health Care Delivery Model? Maria T. Currier Randy Fenninger Holland & Knight LLP Adventist Health System Annual Legal Retreat October 25, 2010 Orlando,

More information

Physician Integration Models: ACOs as the Latest and Greatest? David T. Lewis david.lewis@lpnt.net LifePoint Hospitals, Inc.

Physician Integration Models: ACOs as the Latest and Greatest? David T. Lewis david.lewis@lpnt.net LifePoint Hospitals, Inc. Physician Integration Models: ACOs as the Latest and Greatest? David T. Lewis david.lewis@lpnt.net LifePoint Hospitals, Inc. Brentwood, TN Kim Harvey Looney kim.looney@wallerlaw.com Waller Lansden Dortch

More information

Accountable Care Organizations: An old idea with new potential. Stephen E. Whitney, MD, MBA Testimony to Senate State Affairs September 22, 2010

Accountable Care Organizations: An old idea with new potential. Stephen E. Whitney, MD, MBA Testimony to Senate State Affairs September 22, 2010 Accountable Care Organizations: An old idea with new potential Stephen E. Whitney, MD, MBA Testimony to Senate State Affairs September 22, 2010 Impetus for ACO Formation Increased health care cost From

More information

Cms Finally speaks: organization (ACO) proposed regulations and WhaT They mean For anesthesiologists

Cms Finally speaks: organization (ACO) proposed regulations and WhaT They mean For anesthesiologists ANESTHESIA BUSINESS CONSULTANTS SUMMER 2011 VOLUME 16, ISSUE 2 Cms Finally speaks: The accountable Care organization (ACO) proposed regulations and WhaT They mean For anesthesiologists Since the passage

More information

Medicare ACO Road Map

Medicare ACO Road Map PYALeadership Briefing Medicare ACO Road Map January, 2013 Medicare ACO Road Map The Centers for Medicare & Medicaid Services ( CMS ) has announced 106 new accountable care organizations ( ACOs ) have

More information

SHARED SAVINGS PROGRAM

SHARED SAVINGS PROGRAM 313 PPACA (Consolidated) Sec. 3022\1899 SSA and of individuals described in subsection (a)(4)(a)(ii) participating in such models and payments made under applicable titles for services on behalf of such

More information

December 3, 2010. Donald M. Berwick, M.D. Administrator Centers for Medicare and Medicaid Services Posted to Regulations.gov. File code CMS-1345-NC

December 3, 2010. Donald M. Berwick, M.D. Administrator Centers for Medicare and Medicaid Services Posted to Regulations.gov. File code CMS-1345-NC December 3, 2010 Donald M. Berwick, M.D. Administrator Centers for Medicare and Medicaid Services Posted to Regulations.gov File code CMS-1345-NC Dear Dr. Berwick: The American Urological Association (AUA),

More information

Accountable Care Organizations: Importance to Physicians in Value Based Payment June 19, 2014 12:00-1:00pm EST

Accountable Care Organizations: Importance to Physicians in Value Based Payment June 19, 2014 12:00-1:00pm EST Accountable Care Organizations: Importance to Physicians in Value Based Payment June 19, 2014 12:00-1:00pm EST Ahmed Haque, Director of Care Transformation Health IT U.S. Department of Health & Human Services

More information

Newsroom. The quality measures are organized into four domains:

Newsroom. The quality measures are organized into four domains: Newsroom People with Medicare will be able to benefit from a new program designed to encourage primary care doctors, specialists, hospitals, and other care providers to coordinate their care under a final

More information

Accountable Care Organizations: Forging Stakeholder Partnerships for Health Care Performance and Efficiency

Accountable Care Organizations: Forging Stakeholder Partnerships for Health Care Performance and Efficiency Accountable Care Organizations: Forging Stakeholder Partnerships for Health Care Performance and Efficiency Julie Lewis Director of Health Policy Dartmouth Institute for Health Policy and Clinical Practice

More information

AHLA. BB. Accountable Care Organizations and the Medicare Shared Savings Program. Troy Barsky Crowell & Moring LLP Washington, DC

AHLA. BB. Accountable Care Organizations and the Medicare Shared Savings Program. Troy Barsky Crowell & Moring LLP Washington, DC AHLA BB. Accountable Care Organizations and the Medicare Shared Savings Program Troy Barsky Crowell & Moring LLP Washington, DC Daniel F. Murphy Bradley Arant Boult Cummings LLP Birmingham, AL Terri L.

More information

HEALTHCARE REFORM OCTOBER 2012

HEALTHCARE REFORM OCTOBER 2012 HEALTHCARE REFORM Tracking ACO Growth Nationally OCTOBER 2012 The enclosed slides are intended to provide you with a snapshot of how private sector accountable care organizations (ACOs) have formed since

More information

G-2. Report. Compliance. An ambitious health reform subtitle, Transforming the Health

G-2. Report. Compliance. An ambitious health reform subtitle, Transforming the Health G-2 Kimberly Scott, Managing Editor, kscott@ioma.com Carrie Valiant is a senior member of the health care and life sciences practice of the national law firm, EpsteinBeckerGreen, practicing in its Washington,

More information

ACOs: Fraud & Abuse Waivers and Analysis

ACOs: Fraud & Abuse Waivers and Analysis ACOs: Fraud & Abuse Waivers and Analysis Robert G. Homchick and Sarah Fallows Davis Wright Tremaine, LLP I. Introduction The Patient Protection and Affordable Care Act of 2010 (ACA) fosters the development

More information

DRAFT NCMS POLICY (v. 7) Accountable Care Organizations

DRAFT NCMS POLICY (v. 7) Accountable Care Organizations DRAFT NCMS POLICY (v. 7) Accountable Care Organizations Background: Accountable Care Organizations (ACOs) are an emerging health care delivery model comprised of groups of providers that join together

More information

M E M O R A N D U M. CMS Proposed Rule & Related Agency Notices on Accountable Care Organizations

M E M O R A N D U M. CMS Proposed Rule & Related Agency Notices on Accountable Care Organizations 1501 M Street NW Seventh Floor Washington, DC 20005-1700 Tel: 202.466.6550 Fax: 202.785.1756 M E M O R A N D U M To: From: Clients and Friends Powers Pyles Sutter & Verville, PC Date: April 10, 2011 Re:

More information

Health Policy Brief. Accountable Care Organizations.

Health Policy Brief. Accountable Care Organizations. www.healthaffairs.org 1 Health Policy Brief updated: august 13, 2010 Accountable Care Organizations. Under the health reform law, Medicare will be able to contract with these to provide care to enrollees.

More information

Center for Medicare and Medicaid Innovation

Center for Medicare and Medicaid Innovation Center for Medicare and Medicaid Innovation Summary: Establishes within the Centers for Medicare and Medicaid Services (CMS) a Center for Medicare & Medicaid Innovation (CMI). The purpose of the Center

More information

Legal & Policy Issues Related to ACO Formation by Independent Physician Groups

Legal & Policy Issues Related to ACO Formation by Independent Physician Groups Legal & Policy Issues Related to ACO Formation by Independent Physician Groups Troy Barsky Arthur Lerner Crowell & Moring LLP America s Health Insurance Plans ACO Summit May 15, 2013 Background Government

More information

Guidance Released on Accountable Care Organizations Participating in the Medicare Shared Savings Program

Guidance Released on Accountable Care Organizations Participating in the Medicare Shared Savings Program M A Y 2 0 1 1 Guidance Released on Accountable Care Organizations Participating in the Medicare Shared Savings Program On March 31, 2011, the Centers for Medicare & Medicaid Services (CMS), the Department

More information

Mar. 31, 2011 (202) 690-6145. Summary of proposed rule provisions for Accountable Care Organizations under the Medicare Shared Savings Program

Mar. 31, 2011 (202) 690-6145. Summary of proposed rule provisions for Accountable Care Organizations under the Medicare Shared Savings Program DEPARTMENT OF HEALTH & HUMAN SERVICES Centers for Medicare & Medicaid Services Room 352-G 200 Independence Avenue, SW Washington, DC 20201 Office of Media Affairs MEDICARE FACT SHEET FOR IMMEDIATE RELEASE

More information

STRATEGIC INNOVATIONS FOR AFFORDABLE, SUSTAINABLE HEALTH CARE:

STRATEGIC INNOVATIONS FOR AFFORDABLE, SUSTAINABLE HEALTH CARE: January 2011 STRATEGIC INNOVATIONS FOR AFFORDABLE, SUSTAINABLE HEALTH CARE: A Model for Health System Reform Environmental Scan Accountable Care Organizations Table of Contents ACCOUNTABLE CARE ORGANIZATIONS...

More information

Client Advisory. CMS Issues Final ACO Regulations EXECUTIVE SUMMARY. Health Care. Eligibility. November 10, 2011

Client Advisory. CMS Issues Final ACO Regulations EXECUTIVE SUMMARY. Health Care. Eligibility. November 10, 2011 Client Advisory Health Care November 10, 2011 CMS Issues Final ACO Regulations After receiving more than 1,300 public comments on its Proposed Rule for Accountable Care Organizations (ACOs) under the Medicare

More information

Medicare and Commercial Accountable Care Organizations: A Retrospective and Prospective View

Medicare and Commercial Accountable Care Organizations: A Retrospective and Prospective View Medicare and Commercial Accountable Care Organizations: A Retrospective and Prospective View Troy Barsky, Esq. Jennifer Williams, Esq. Crowell & Moring Daniel Murphy, Esq. Bradley Arant Boult & Cummings

More information

CMS ACO Proposed Regulations

CMS ACO Proposed Regulations CMS ACO Proposed Regulations May 2011 Proposed CMS ACO Regulations Proposed Regulations issued March 31, 2011 Comments due back June 6, 2011 Requires 3 year binding commitment Formal Legal Structure Required

More information

Large Urology Group Practice Association. Accountable Care Organizations

Large Urology Group Practice Association. Accountable Care Organizations Large Urology Group Practice Association Accountable Care Organizations November 6, 2010 J. Phillip O Brien 312.902.5630 phillip.obrien@kattenlaw.com Basic Premise for ACOs Facilitate medical care coordination

More information

Accountable Care Organizations. Rick Shinto, MD Aveta Health Inc. July 20, 2010

Accountable Care Organizations. Rick Shinto, MD Aveta Health Inc. July 20, 2010 Accountable Care Organizations Rick Shinto, MD Aveta Health Inc. July 20, 2010 1 Health Care Reform- New Models of Care Patient Protection and Affordable care Act (PPACA 2010) controlling costs and improving

More information

Accountable Care Organizations and Provider Integration Under Health Care Reform. Sarah Swank 202.326.5003 seswank@ober.com

Accountable Care Organizations and Provider Integration Under Health Care Reform. Sarah Swank 202.326.5003 seswank@ober.com Accountable Care Organizations and Provider Integration Under Health Care Reform Sarah Swank 202.326.5003 seswank@ober.com February 26, 2014 Overview Affordable Care Act and ACOs Trends in Integration

More information

Advancing Accountable Care

Advancing Accountable Care Advancing Accountable Care April 19, 2012 S. Lawrence Kocot, JD, LLM, MPA Deputy Director, Engelberg Center for Health Care Reform; Senior Counsel, SNR Denton Sean McBride Project Manager, Engelberg Center

More information

ACCOUNTABLE CARE ORGANIZATIONS

ACCOUNTABLE CARE ORGANIZATIONS ACCOUNTABLE CARE ORGANIZATIONS Implementing Efficient, Value-Based Health Care Programs Prepared by Sara Watson September 2010 Table of Contents Abstract.. pg. 2 Overview.pg. 2-3 Background...pg. 2-3 Introduction...pg.

More information

Legal Waivers under the Medicare Shared Savings Program: An Overview of the Options

Legal Waivers under the Medicare Shared Savings Program: An Overview of the Options Legal Waivers under the Medicare Shared Savings Program: An Overview of the Options Robert G. Homchick Davis Wright Tremaine LLP Arthur N. Lerner Crowell & Moring LLP Shared Savings Program: ACOs Medicare

More information

Accountable Care Organizations: The Final Rule

Accountable Care Organizations: The Final Rule Accountable Care Organizations: The Final Rule October 27, 2011 2011 Akin Gump Strauss Hauer & Feld LLP 10.27.11 101799002 v4 Overview Background Final Rule Highlights Structure and Formation of ACOs Quality

More information

Summary of Final Rule Provisions for Accountable Care Organizations under the Medicare Shared Savings Program

Summary of Final Rule Provisions for Accountable Care Organizations under the Medicare Shared Savings Program DEPARTMENT OF HEALTH AND HUMAN SERVICES Centers for Medicare & Medicaid Services Summary of Final Rule Provisions for Accountable Care Overview The Centers for Medicare & Medicaid Services (CMS), an agency

More information

Accountable Care Organizations

Accountable Care Organizations Building a Healthy ACO Compliance Program HCCA 2014 Compliance Institute Mary C. Malone, Esq. Hancock, Daniel, Johnson & Nagle, P.C. Disclaimer: The content of this presentation does not constitute legal

More information

Accountable Care Organizations & Other Reimbursement Reforms: The Impact on Physician Practices

Accountable Care Organizations & Other Reimbursement Reforms: The Impact on Physician Practices Accountable Care Organizations & Other Reimbursement Reforms: The Impact on Physician Practices Martin Bienstock, Esq. Wilson Elser Martin.Bienstock@WilsonElser.com The New York Times Take... For the first

More information

Telemedicine in the Patient Protection and Affordable Care Act (2010)

Telemedicine in the Patient Protection and Affordable Care Act (2010) Telemedicine in the Patient Protection and Affordable Care Act (2010) The new national health insurance reform legislation contains several advances for telemedicine that are listed below. There are numerous

More information

Health Care Reform Implementation and Improving Cancer Care

Health Care Reform Implementation and Improving Cancer Care Health Care Reform Implementation and Improving Cancer Care Mark McClellan, MD, PhD Senior Fellow and Director, Initiatives on Value and Innovation in Health Care Brookings Institution Mark McClellan.

More information

Post-Acute/Long- Term Care Planning for Accountable Care Organizations

Post-Acute/Long- Term Care Planning for Accountable Care Organizations White Paper Post-Acute/Long- Term Care Planning for Accountable Care Organizations SCORE A Model for Using Incremental Strategic Positioning as a Planning Tool for Participation in Future Healthcare Integrated

More information

E. Christopher Ellison, MD, F.A.C.S Senior Associate Vice President for Health Sciences

E. Christopher Ellison, MD, F.A.C.S Senior Associate Vice President for Health Sciences Accountable Care Organizations and You E. Christopher Ellison, MD, F.A.C.S Senior Associate Vice President for Health Sciences CEO, OSU Faculty Group Practice Chair, Department of Surgery Ohio State University

More information

1900 K St. NW Washington, DC 20006 c/o McKenna Long

1900 K St. NW Washington, DC 20006 c/o McKenna Long 1900 K St. NW Washington, DC 20006 c/o McKenna Long Centers for Medicare & Medicaid Services U. S. Department of Health and Human Services Attention CMS 1345 P P.O. Box 8013, Baltimore, MD 21244 8013 Re:

More information

ACCOUNTABLE CARE ORGANIZATION (ACO): SUPPLYING DATA AND ANALYTICS TO DRIVE CARE COORDINATION, ACCOUNTABILITY AND CONSUMER ENGAGEMENT

ACCOUNTABLE CARE ORGANIZATION (ACO): SUPPLYING DATA AND ANALYTICS TO DRIVE CARE COORDINATION, ACCOUNTABILITY AND CONSUMER ENGAGEMENT ACCOUNTABLE CARE ORGANIZATION (ACO): SUPPLYING DATA AND ANALYTICS TO DRIVE CARE COORDINATION, ACCOUNTABILITY AND CONSUMER ENGAGEMENT MESC 2013 STEPHEN B. WALKER, M.D. CHIEF MEDICAL OFFICER METRICS-DRIVEN

More information

August 12, 2010. Dear Dr. Berwick:

August 12, 2010. Dear Dr. Berwick: Donald M. Berwick, MD Administrator Centers for Medicare and Medicaid Services Department of Health and Human Services 200 Independence Avenue, SW Room 314G Washington, DC 20201 Dear Dr. Berwick: I am

More information

Accountable Care Organizations and Market Power Issues

Accountable Care Organizations and Market Power Issues Accountable Care Organizations and Market Power Issues October, 2010 Introduction Accountable care organizations (ACOs) have received significant attention since passage of the Patient Protection and Affordable

More information

The Journey to Population Health Management: A Capability Framework and Assessment for Accountable Care

The Journey to Population Health Management: A Capability Framework and Assessment for Accountable Care The Journey to Population Health Management: A Capability Framework and Assessment for Accountable Care DISCLAIMER: The views and opinions expressed in this presentation are those of the author and do

More information

Amy K. Fehn. I. Overview of Accountable Care Organizations and the Medicare Shared Savings Program

Amy K. Fehn. I. Overview of Accountable Care Organizations and the Medicare Shared Savings Program IMPLEMENTING COMPLIANCE PROGRAMS FOR ACCOUNTABLE CARE ORGANIZATIONS Amy K. Fehn I. Overview of Accountable Care Organizations and the Medicare Shared Savings Program The Medicare Shared Savings Program

More information

DEPARTMENT OF HEALTH AND HUMAN SERVICES

DEPARTMENT OF HEALTH AND HUMAN SERVICES DEPARTMENT OF HEALTH AND HUMAN SERVICES Centers for Medicare & Medicaid Services 42 CFR Chapter IV Office of Inspector General 42 CFR Chapter V [CMS-1439-IFC] RIN 0938-AR30 Medicare Program; Final Waivers

More information

Accountable Care Organizations: Experiences, Examples and Lessons Learned

Accountable Care Organizations: Experiences, Examples and Lessons Learned Accountable Care Organizations: Experiences, Examples and Lessons Learned New York State Academy of Family Physicians Downstate Regional Family Medicine Conference Jeffrey R. Ruggiero Arnold & Porter LLP

More information

December 3, 2010. Dear Administrator Berwick:

December 3, 2010. Dear Administrator Berwick: Donald Berwick, M.D. Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services Room 445-G, Hubert H. Humphrey Building 200 Independence Avenue, SW Washington, DC 20201

More information

Mark McClellan Engelberg Center for Health Care Reform Brookings Institution. Key ACO Principles

Mark McClellan Engelberg Center for Health Care Reform Brookings Institution. Key ACO Principles Mark McClellan Engelberg Center for Health Care Reform Brookings Institution Key ACO Principles ACO Congress Agenda Over the next few days the Congress will examine: 1. How ACOs fit into health care reform

More information

Look Before You Leap: Legal and Practical Obstacles with ACOs

Look Before You Leap: Legal and Practical Obstacles with ACOs Look Before You Leap: Legal and Practical Obstacles with ACOs Houston ACO Conference May 7, 2013 Edward Vishnevetsky, Esq. Coordinated Care and ACOs Coordinated Care Goal: ensure that healthcare providers

More information

Brief Course. Neil Kirschner, Ph.D. Director, Regulatory and Insurer Affairs

Brief Course. Neil Kirschner, Ph.D. Director, Regulatory and Insurer Affairs Accountable Care Organization (ACO) 101 Brief Course Neil Kirschner, Ph.D. Director, Regulatory and Insurer Affairs What is an ACO? ACO refers to a legal entity composed of a group of providers that assume

More information

Current Issues in Medicare

Current Issues in Medicare Current Issues in Medicare Stuart Guterman Senior Program Director Program on Medicare s Future The Commonwealth Fund Health Care Delivery Policy Meeting Cambridge, MA October 27, 2006 Current Issues Update

More information

Issue Brief. Raising the Bar. Standards for Accountable Care Organizations to Truly Improve Health Care Quality and Affordability in the United States

Issue Brief. Raising the Bar. Standards for Accountable Care Organizations to Truly Improve Health Care Quality and Affordability in the United States Raising the Bar Standards for Accountable Care Organizations to Truly Improve Health Care Quality and Affordability in the United States Issue Brief Introduction Health care costs continue to rise at an

More information

CPCA California Primary Care Association

CPCA California Primary Care Association CPCA California Primary Care Association Accountable Care Organizations: Next Generation Systems for Community Health Centers? CPCA Annual Conference Sacramento, California October 10, 2014 Larry Garcia,

More information

Summary of the Major Provisions in the Patient Protection and Affordable Health Care Act

Summary of the Major Provisions in the Patient Protection and Affordable Health Care Act Summary of the Major Provisions in the Patient Protection and Affordable Care Act Updated 10/22/10 On March 23, 2010, President Barack Obama signed into law comprehensive health care reform legislation,

More information

OUR ACCOUNTABLE CARE ORGANIZATION (ACO) STRATEGY. Meredith Marsh Director Health Choice Care, LLC

OUR ACCOUNTABLE CARE ORGANIZATION (ACO) STRATEGY. Meredith Marsh Director Health Choice Care, LLC OUR ACCOUNTABLE CARE ORGANIZATION (ACO) STRATEGY Meredith Marsh Director Health Choice Care, LLC HEALTH REFORM The Affordable Care Act (ACA) strives to achieve the Triple AIM: Improving the experience

More information

Healthcare Reform and Accountable Care Organizations

Healthcare Reform and Accountable Care Organizations Advisor Live Executive Summary from August 18, 2010 program: Healthcare Reform and Accountable Care Organizations Speakers: Wes Champion, senior vice president, Premier Consulting Solutions Mark Rumans,

More information

January 3, 2012. RE: Comments submitted at http://www.regulations.gov.

January 3, 2012. RE: Comments submitted at http://www.regulations.gov. January 3, 2012 RE: Comments submitted at http://www.regulations.gov. Marilyn Tavenner, Acting Administrator U.S. Department of Health and Human Services Centers for Medicare and Medicaid Services Attention:

More information

ACOs: What They Are and How They Work? MedChi Facts 9/17/2014. MedChi Works to Enhance Health Care for All Marylanders

ACOs: What They Are and How They Work? MedChi Facts 9/17/2014. MedChi Works to Enhance Health Care for All Marylanders ACOs: What They Are and How They Work? Maryland MGMA Annual Conference Gene Ransom CEO, MedChi September 19, 2014 MedChi Facts MedChi is the seventh oldest medical society, formed in 1799 in Annapolis,

More information

RE: CMS 1461-P; Medicare Shared Savings Program: Accountable Care Organizations

RE: CMS 1461-P; Medicare Shared Savings Program: Accountable Care Organizations 221 MAIN STREET, SUITE 1500 SAN FRANCISCO, CA 94105 PBGH.ORG OFFICE 415.281.8660 FACSIMILE 415.520.0927 February 6, 2015 Marilyn Tavenner Administrator Centers for Medicare and Medicaid Services 7500 Security

More information

Learning What It Takes to Form Successful Accountable Care Organizations

Learning What It Takes to Form Successful Accountable Care Organizations Session: Medicare ACOs: What s Needed to Make Them Work? Learning What It Takes to Form Successful Accountable Care Organizations Insight from Premier s PACT (Partnership for Care Transformation) Collaboratives

More information